UPC Analytics
ENDE
Overview · Filed: May 2, 2025

UPC_CFI_387/2025

ATTACHMENT FOR A HAND HELD APPLIANCE

Provisional measuresProvisional MeasuresHamburg LDProvisional measuresCase Closed
OverviewDecisionsReasoningCitationsDocumentsTimeline
Plain-English summary

Dyson Technology Limited obtained a preliminary injunction from the Hamburg Local Division against Dreame International (HK) and related Dreame entities for infringement of EP 3 119 235 (hair attachment for handheld appliances such as hair dryers). The decision established that EU-mandated Authorized Representatives can serve as both anchor defendants and intermediaries subject to injunctions under Art. 63(1) UPCA, and that the UPC has jurisdiction over all infringements in UPC member states regardless of defendant domicile, with costs shared equally as Dyson succeeded on only half its claims.

Accepted arguments
What the court agreed with — by party.

  • UPC has jurisdiction regardless of defendant's domicile for infringements in UPC member states

    ClaimantLegal basis: Art. 71b(2) UPCA; Art. 7(2) Brussels I recast (1215/2012/EU)

    Note: Court affirmed UPC's cross-border jurisdiction as a common court, extending beyond traditional domicile-based rules.

  • Claims against non-EU defendants are closely connected within the same defendant group, enabling joinder under Art. 8(1) Brussels I

    ClaimantLegal basis: Art. 8(1) Brussels I recast (1215/2012/EU)

    Note: Where defendants not domiciled or active in Germany are part of the same corporate group attacking the same embodiments, claims are closely connected.

  • EU-mandated Authorized Representative (Eurep GmbH) qualifies as anchor defendant under Art. 8(1) Brussels I and as intermediary subject to injunction under Art. 63(1) UPCA

    ClaimantLegal basis: Art. 63(1) UPCA; Regulations 2023/988/EU and 2019/1020/EU; Art. 8(1) Brussels I recast

    Note: Court found that non-EU manufacturers cannot sell electronics in the EU without an Authorized Representative, making such representative an indispensable party in the distribution chain and thus both an anchor defendant and an intermediary subject to injunction.

  • Direct infringement of EP 3 119 235 claims 1 and 11 by Dreame's hair attachment for handheld appliance

    ClaimantLegal basis: EP3119235 claims 1 and 11

    Note: Court granted PI against Defendants 1, 2, and 4 for direct infringement of the Dyson Airwrap-style attachment within UPCA territory, and against Defendants 1 and 3 also with respect to Spain.

Rejected arguments
What the court did not agree with — and why.

  • Application for provisional measures as to remaining embodiments (second group of attacked products)

    ClaimantLegal basis: Art. 62 UPCA

    Reason: Applicant succeeded with only one of two groups of attacked embodiments; the remaining part of the application was dismissed without further explanation in the available excerpt.

  • International jurisdiction for Spanish national part of Defendant 4 (Dreame Technology AB)

    ClaimantLegal basis: Art. 71b(2) UPCA; Art. 7(2) Brussels I recast

    Reason: Court required at least a plausible allegation of infringing acts by the specific party in Spain; Defendant 4 did not meet this threshold.

Key legal principles
Doctrines and rules cited in the reasoning.
UPC jurisdiction regardless of defendant's domicile (Art. 71b(2) UPCA)anchor defendant and close connection under Art. 8(1) Brussels I recastEU Authorized Representative as intermediary under Art. 63(1) UPCAEU Authorized Representative as anchor defendant in patent infringement proceedingsplausible allegation of infringing acts required for national part jurisdictionno enforcement security required where applicant is a well-known manufacturer

Browse other cases on this principle.

Claim construction notes

The injunction order reproduces the claim text of EP 3 119 235 claims 1 and 11 verbatim (tubular hair attachment with overlapping slot, Coanda effect fluid outlet), indicating these were the construed scope applied to Dreame's products. No specific disputed terms or divergent constructions are recorded in the excerpt.